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Burger King Corp. v. Rudzewicz

(1985)

Supreme Court of the United States - 471 U.S. 462

tl;dr:

A party need not be physically present in the forum state for personal jurisdiction to arise

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ICRAIssue, Conclusion, Rule, Analysis for Burger King Corp. v. Rudzewicz

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Facts & HoldingBurger King Corp. v. Rudzewicz case brief facts & holding

Facts:Burger King is a Florida corporation with principal offices in...

Holding:To decide if personal jurisdiction exists in a contract case,...

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Burger King Corp. v. Rudzewicz | Case Brief DeepDive
Majority opinion, author: Justice Brennan
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The case involves a dispute between a Michigan resident and Burger King Corporation over a franchise agreement. The District Court found personal jurisdiction over the defendants and entered judgment against them, but the Eleventh Circuit reversed the decision. The Supreme Court established that a forum may have personal jurisdiction over a nonresident who purposefully directs their activities towards forum residents. The court upheld the District Court's decision to assert personal jurisdiction over Rudzewicz in Florida for the alleged breach of his franchise agreement, stating that it did not violate due process. The minimum requirements of "fair play and substantial justice" may defeat the reasonableness of jurisdiction even if the defendant has purposefully engaged in forum activities.

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Dissenting opinion, author: Justice Stevens
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Justice Stevens dissents from the majority opinion, arguing that it is unjust to require a franchisee to defend a case in a forum chosen by the franchisor. The franchisee in this case had no business presence in Florida and had no significant contacts with the state. The Court's reliance on standard language in documents to establish jurisdiction creates a potential for unfairness in franchise relationships and dispute resolution. The dissenting justice agrees with the Court of Appeals for the Eleventh Circuit's opinion that the franchisee lacked fair notice that Burger King's corporate headquarters in Florida would assert jurisdiction over him in its home state, as all negotiations and supervision were conducted through the Michigan office.

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